Your name is on
a sanctions list — and it's wrong.
A structured Swiss legal review of every major international watch-list — OFAC, EU CFSP, UN Security Council and SECO — followed by a properly-drafted delisting request where the listing is, in fact, a mistake. Most of them are.
◉ Me. Isabelle Chapuis · Lead◉ Sanctions & EU Law◉ EN · DE · FR · RU
★ CONFIDENTIAL · COMPLIANCE SCREENING REPORT · ★
Valken Legal AG
Hardstrasse 127 · BASEL · CH
VK-3921-S
Issued 14·V·2026
Legal Opinion · Watch-List Cross-Reference
Sanctions database assessment.
Subject
CLIENT · REDACTED
DOB / Nationality
19·••·1•78 · XX
Scope
4 databases · 12 sublists
Reviewer
Me. I. Chapuis
I — Database cross-reference
00h 47m · complete
OFAC SDN US Treasury
0.12
CLEAR
EU CFSP Council Reg.
0.09
CLEAR
UN SC 1267 Sanctions Cmt.
0.72
MATCH
SECO CH Swiss Measures
0.08
CLEAR
UK HMT OFSI
0.31
REVIEW
II — Match analysis
Phonetic and transliteration similarity to a designated entry on UN SC 1267. Subject's biographical markers — DOB, nationality, place of residence — do not align with the listed individual. Likely homonym match.
False-positive confidence
LIKELY 72% / 100
Recommended: formal delisting request
III — Preliminary verdict
ACTION
File Section 5 request to the UN 1267 Ombudsperson to establish distinct identity. Estimated 6–9 months.
Me. I. Chapuis
Attorney · Geneva Bar
valken.ch/v/VK-3921-S02 / 09 · cont.
LIVE CASE
Match — likely false
Delisting · in preparation
Before anything else
Most sanctions hits aren't sanctions at all.
Of the clients who come to us convinced their name is "on a sanctions list", roughly four out of five turn out to be something else entirely: a homonym hit, a corporate-screening false positive, an old adverse-media article flagged by an automated engine, or a database echo from a relationship that ended years ago. Our first job is to figure out which one it actually is.
What we actually check
Four primary lists. Twelve sublists. One legal opinion.
"Sanctions database" is a misleading term. There are dozens of separate lists maintained by different jurisdictions, each with its own legal framework and delisting procedure. We review the four that matter most for clients operating anywhere in Europe, the UK, Switzerland or the US financial system.
US
United States
OFAC SDN & Consolidated List
Office of Foreign Assets Control · US Treasury
The most widely-enforced sanctions regime globally. Any US-dollar transaction, any US-connected bank, any US-linked correspondent relationship is screened against OFAC. A match here is the most consequential — and also the one most often triggered by name coincidence.
Listings
13,000+
Sublists
9
Delisting
Form TD F
EU
European Union
EU CFSP Consolidated List
Common Foreign & Security Policy · Council Regulations
The EU's own sanctions framework, separate from OFAC. Every EU bank, every EU payment processor, every EU corporate registry is screened against it. Rapidly expanded since 2022 — and with it, the false-positive rate.
Listings
2,200+
Regimes
40+
Delisting
Art. 275 TFEU
UN
United Nations
UN Security Council Sanctions
Resolutions 1267 / 1988 / 1718 et al.
Binding on all 193 member states — including Switzerland. A UN listing propagates to every national sanctions regime automatically. The delisting mechanism, via the Office of the Ombudsperson, is specific and procedural.
Listings
700+
Ombudsperson
1267 only
Delisting
6–9 months
CH
Switzerland
SECO Swiss Sanctions Register
State Secretariat for Economic Affairs
Switzerland's sovereign sanctions list — largely aligned with the EU, but with meaningful procedural differences. For anyone with Swiss banking exposure or Swiss legal residence, a SECO match has practical consequences that a purely EU listing does not.
Listings
2,000+
Updated
Weekly
Delisting
Art. 17 EmbA
Why your name is flagged
Six reasons a name shows up on a list.
From the most common (and usually fixable) to the least common (and rarely so). If you know which one applies to your situation, you are already halfway to the right legal response.
Most common
Homonym — you share a name with someone sanctioned
Your name, transliterated and phonetically similar, matches an entry on a sanctions list. The matched person is usually a foreign national you've never met. Screening software cannot tell the difference without additional data points.
Example
Clara Müller (Zurich, born 1985) flagged against an OFAC entry for Klara Muller (Belarus, born 1968).
Very common
Adverse-media screening false positive
Not a sanctions match at all — but an old news article, blog post or court document mentioning your name was ingested by a compliance database and is treated by some institutions as if it were a sanctions signal.
Example
A 2014 article misattributing your name to an unrelated business dispute, still cached in a World-Check or Dow Jones-type profile.
Less common
PEP status — politically exposed person
Not technically a sanction, but a status flag that causes heightened scrutiny. Applies to current or former officials, their close family and associates. Often reaches people who did not expect to be classified this way.
Example
Your cousin held a regional government post in 2017–19. You are now screened as a "close associate of a PEP" by some EU banks.
Less common
Entity exposure — a company you were linked to
You are not sanctioned personally, but a legal entity in which you held directorship, shares, or signing authority has been designated. The link propagates to your name in compliance databases.
Example
You exited a board in 2020; the company was designated in 2023. Older registries still record you as a director.
Rare but serious
Actual sanctions designation
Your name has in fact been placed on a sanctions list by a sanctioning body, for reasons they consider attributable to you personally. The legal response is very different and much more procedural.
Example
An explicit SDN or CFSP designation with a published reason and a designation date you can verify.
Rare
Secondary designation — sanction by association
You have not been individually designated, but a transaction, counterparty or structure you used is covered by a sanctions regime. Your compliance record is now flagged as "exposed" even though you're not on any list.
Example
A property you co-owned was used by an unrelated designated person. Secondary-sanctions exposure attaches through that historical link.
Our five-day process
From scan to signed opinion. In five days.
A structured engagement with a clear endpoint. You receive, on day five, a written legal opinion that a European bank's compliance department will actually take seriously — and, where justified, a properly-drafted delisting request ready to file.
01
Day 1
Intake & identity scope
We collect every identifier required for precise screening: full legal names, transliterations, DOB, nationalities, historic addresses, past entity affiliations.
02
Day 2
Multi-database scan
Cross-reference against OFAC, EU CFSP, UN, SECO and UK OFSI lists. Parallel check against adverse-media and PEP databases. Every hit is scored and logged.
03
Day 3
Legal qualification
Each match is legally analysed: is it a homonym, a real designation, a media artefact, a PEP flag? We classify every one, with the legal basis documented.
04
Day 4
Opinion drafting
A signed legal opinion is drafted: scope, findings, classification, recommended action for each hit. Strategy options where delisting is justified.
05
Day 5
Delivery & debrief
Signed opinion delivered. One-hour call with Me. Chapuis to walk through every paragraph. Where action is required, a filing-ready delisting draft is included.
An important distinction. Our 5-day engagement ends with a legal opinion and, where justified, a filing-ready delisting request. The delisting procedure itself — with OFAC, the CFSP Council, the UN Ombudsperson or SECO — sits with the issuing body and takes from weeks to many months depending on the regime. That second phase is quoted separately, and only after you've read the opinion and decided you want it filed.
What we're looking for
False-positive — or real designation? The difference matters.
Every legal strategy flows from this distinction. Confusing one for the other wastes time, money, and in serious cases, your chance at the right procedural remedy.
Most frequent outcome
False positive / homonym hit
Your name is similar — by spelling, phonetics or transliteration — to someone actually on a list. But the biographical markers (DOB, nationality, place, affiliation) don't align when examined carefully.
Biographical markers don't matchDifferent DOB, nationality or residency than the listed entry.
No historical link to the listed personNo shared business, no shared address, no shared entity.
The issuing body has published no designation against youNo reason-for-listing, no designation date, no reference to you.
Legal remedy
"Distinct identity" request / screening-record correction. Typically resolved in 2–8 weeks once the right evidence file is filed. Our opinion alone is often sufficient to clear the flag with a bank.
Rare but serious
Actual designation against you
The sanctioning body has specifically published a reason for listing you. Your name, identifiers and, usually, a justification appear on the record. This is a substantive legal procedure — not a screening error.
Your identifiers match the listed entry preciselyDOB, nationality and place align with the designation.
A published statement of reasons existsThe issuing body has explained why you are listed.
You may have received a notification letterFrom OFAC, the CFSP Council, or a national authority.
Legal remedy
Formal delisting petition under the regime-specific procedure (OFAC reconsideration, CFSP annulment action at the GC, UN Ombudsperson under SC 1904). Typically 6–18 months, and a separate legal engagement.
What you receive
A signed legal opinion. Not a screenshot.
The difference between a legal opinion and an automated screening report is the difference between a document a bank will act on — and one it will politely ignore.
Legal opinion — 8 to 12 pages
Scope, methodology, database-by-database findings, legal classification of each hit, recommended action. Signed by Me. Isabelle Chapuis under Geneva Bar responsibility.
Draft delisting / correction request
Where the analysis justifies it, a filing-ready draft addressed to the appropriate authority (OFAC, CFSP, UN Ombudsperson, SECO). Ready to sign or adapt.
Raw screening evidence file
The database extracts we ran, time-stamped. Useful if you ever need to demonstrate to a bank or counterparty exactly what was checked and when.
60-minute debrief call
Direct with Me. Chapuis, by encrypted video or voice. Every classification walked through with you, every option explained in plain language.
Office of Foreign Assets Control
U.S. Department of the Treasury
1500 Pennsylvania Ave NW
Washington DC · 20220
14 May 2026
Via TD-F secure submission
Re: VK-3921-S · Art. 501(a) reconsideration
Request for distinct-identity confirmation — false-positive screening remediation.
On behalf of the Subject (identified under separate cover), we respectfully submit that the automated screening match flagged against SDN entry dated 11·III·2018 is not substantiated by biographical alignment.
Date of birth, nationality, place of residence and employment history of the Subject materially differ from those of the designated individual, as evidenced by the documentation attached hereto (Exhibits A–F).
We therefore request formal confirmation of distinct identity pursuant to §501(a)(1)(iii) of the applicable regulations, so that the Subject may be removed from the screening population of correspondent institutions.
I. Chapuis
Me. Isabelle Chapuis
Valken Legal AG
BASEL · CHE-299.308.181
Who this is for
The Sanctions Check is the right service when…
This is a diagnostic-and-action engagement. It is designed for people who suspect, have been told, or have evidence that their name is appearing somewhere it shouldn't — and who need a definitive, signed legal answer about it.
A bank told you there's a "sanctions concern"
Compliance mentioned a list match in writing or verbally, and you need to know what it actually is — and how to clear it.
Multiple providers have refused you "for internal reasons"
A bank, a payment processor, a broker, a crypto exchange — more than one has declined onboarding without a substantive reason.
Transfers are being blocked at the correspondent level
Your money leaves, then bounces back days later with a vague reference to "compliance screening" in the SWIFT reject code.
You were shown your own file in a compliance database
A friendly banker or compliance officer told you "your name is in there" and you'd like to know what "there" actually means.
A past relationship or entity concerns you
You held shares, a directorship or signing authority in a company that was later designated — or was a counterparty of one.
You received an OFAC / CFSP / SECO letter
A formal notification has arrived. This is not a screening issue — it is a substantive designation, and the response windows are strict.
Three different European banks had been treating me like a sanctioned person for over a year. Nobody would tell me why. Valken's Me. Chapuis traced it to a homonym match — a name three letters away from mine, attached to an old UN listing. Four weeks after her opinion went out, two of the three banks cleared me. The third took twelve weeks. Either way: I can move money again.
The official lists are technically public and searchable. You will not, however, find what you're actually looking for: which automated screening tool is flagging you, what score it assigned, what biographical vectors triggered the match, which secondary database (World-Check, Dow Jones, LexisNexis) mirrors it, and — most importantly — what legal status your record actually has. A bank's compliance department is not looking at the public OFAC website; it is looking at a commercial aggregator that behaves differently. Our review looks at what they see.
If the match is a false positive, why can't the bank just "see" that?
Banks operate under a defensive logic: when an automated system raises a flag, clearing it internally requires a documented, auditable reason. Saying "the client says it's not him" is not acceptable to their internal audit or to regulators. A signed legal opinion from a Swiss firm explaining, on the record, why the match is a homonym — with evidence — is exactly the kind of document that satisfies their audit trail. That's what we provide.
How is this different from the Bank Freeze Review?
The Bank Freeze Review focuses on a single institution's specific action and the response to that institution. The Sanctions Check works the other way around: it diagnoses the underlying database records that may be causing multiple institutions to treat you in a certain way. Clients often do one, then the other — or, if we diagnose early, they never need the first.
Is €1,900 the total cost, or does the actual delisting cost more?
€1,900 covers the 5-day engagement: four-database cross-reference, legal opinion, draft delisting request, debrief. If the finding is false-positive — which is most cases — that opinion is often, in itself, enough to clear the flag with a bank. If actual procedural delisting with OFAC, the CFSP Council or the UN Ombudsperson is needed, that is a separate engagement, quoted upfront and capped where possible. You are never in an open-ended meter.
How long until I'm actually "cleared"?
Honestly — it depends on the category and the issuing body. For homonym/false-positive cases where the action happens at the bank level, 2–8 weeks is typical after the opinion is delivered. For formal delisting at OFAC, typically 3–9 months. At the UN Ombudsperson, 6–9 months on average. At the EU Council, through the General Court, 12–18 months. We give you the realistic number for your category on day five, not a marketing figure.
I'm not European and I'm not in Switzerland. Do you still help me?
Yes — this is the majority of this practice. We regularly work with clients from the Middle East, Asia, Eastern Europe and the Americas whose exposure is to European or US sanctions regimes. Our licensure is Swiss; the frameworks we deal with are international. Almost all of this work is done remotely under encrypted channels.
What do you actually need from me to run the check?
Full legal name (and any transliteration or alias variants), date and place of birth, nationality(ies), current and prior residences over the last ten years, principal past employers or entities you were associated with, and a copy of the communication from the bank or third party that prompted the concern, if any. Everything is protected by Swiss professional secrecy from the first message and stored only on Swiss-hosted infrastructure.
Is this confidential? Will the listing body know I am being represented?
The review itself is fully confidential — the engagement, the opinion, the findings. The delisting procedure, if you choose to file one, is a formal administrative procedure before a named authority, and at that stage the representation is by definition disclosed to that authority (and only to them). Your underlying details remain under professional secrecy and data-protection rules throughout.
Read before you decide
Related Valken briefings.
Background reading that helps people decide whether a Sanctions Check is the right first step — or whether another service fits the situation better.
Find out what the lists actually say about you — on the record.
Guessing is expensive. Suspecting is worse. Five days from now you can have a signed legal opinion telling you exactly what is — and, more often, what isn't — in the major international watch-lists under your name.